ML19308C990

Fourth Set of Interrogatories Directed to Nrc.Requests Identification of All Transcomm,Inc Documents Provided to NRC in Connection W/Proceeding

ML19308C990
Person / Time
Site:	South Texas, Comanche Peak
Issue date:	02/01/1980
From:	Franklin W HOUSTON LIGHTING & POWER CO., LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19308C991	List: ML19308C990 ML19308C997 ML19308D002
References
NUDOCS 8002130047
Download: ML19308C990 (5)

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ets a1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD A ' O*

In the Matter of )

)

HOUSTON LIGHTING & POWER ) Docket Nos. 50-498A COMPANY, et al. ) 50-499A

)

(South Texas Project, )

Units 1 and 2) )

)

TEXAS UTILITIES GENERATING ) Docket Nos. 50-445A COMPANY, et al. ) 50-($bA

)

(Comanche Peak Steam Electric )

Station, Units 1 and 2) )

FOURTH SET OF INTERROGATORIES FROM HOUSTON LIGHTING & POWER COMPANY TO NRC STAFF Preface Pursuant to Sections 2.720, 2.740, and 2.790 of the Commission's Rules of Practice, Houston Lighting & Power Company propounds the following Interrogatories to the NRC Staff (" Staff"). Each Interrogatory should be answered separately and fully in writing under oath or affirmation by the person or persons making them no later than 14 days after service of these Interrogatories.

Definitions As used herein the terms listed below are, unless otherwise specifically indicated, intended to have the following meanings:

8002180 O

4

1. "First Set" refers to the First Set of Interrogatories and Requests for Production of Documents from Houston Lighting

& Power Company to NRC Staff, dated October 17, 1978. ,

2. All Definitions of the First Set are incorporated in these Definitions by reference.

3. "This proceeding" means the above-captioned four Dockets.

General Instructions The following General Instructions apply to each of the discovery requests contained herein:

1. Restate the interrogatory as the first part of the

! answer.

2. All General Instructions of the First Set are incorporated in these General Instructions by reference.

3. Exclude from your answer identification of all documents which the Staff has previously produced to Houston.

'l Interrogatories

1. Identify all documents which Transcomm Inc., Dr.

N.C. Lerner, Rodney W. Frame, Antoinette Crowder, Kathy Rchbein, or any other Transcomm Inc employee or consultant has provided to the Staff in connection with this proceeding.

Identify documents in the possession or control of any entity or person named or described in this Interrogatory to which the Staff has or had access, whether or not-any such document has ever been in the possession or control of the Staff.

2 . Identify all documents which the Staff has provided to Transcomm Inc., Dr. N.C. Lerner, Rodney W. Frame, Antoinette Crowder, Kathy Rehbein, or any other Transcomm Inc. employee or consultant in connection with this proceeding. Identify documents in the possession or control of the Staff to which any entity or person named or described in this Interrogatory has or had access, whether or not any such document has ever been in the possession or control of such entity or person.

3. Identify all Requests for Proposals, proposals, bids, contracts, contract amendments, evaluations, and progress reports which relate to work performed or to be performed in connection with this proceeding by Transcomm Inc., Dr. N.C.

Lerner, or any other employee of Transcomm Inc.

4. State the date of each oral communication between the Staff and its expert witness, Dr. N. C. Lerner or any person assisting him in connection with this proceeding, and for each such communication:

(a) Identify each party thereto; (b) State the subject matter of the communication; (c) State what was said by each party;.and (d) Identify all documents which set forth, contain information about, relate to or were discussed in the communication.

5. State the date of each oral communication between the Staff and its expert witness Robert Hartley or any person assisting him in connection with thia proceeding, and for each

! such communication:

l  !

+

e (a) Identify each party thereto; (b) State the subject matter of the communication; (c) State what was said by each party; and ,

(d) Identify all documents which set forth, contain information about, relate to or were discussed in the communication.

6. Identify all documents which contain information about, refer or relate to any of the following memoranda or the purpose for which they were prepared:

(a) The Transcomm Memorandum to File from Rod Frame dated March 29, 1979, entitled " South Texas Antitrust Case";

(b) The Memorandum to File from Rod Frame dated April 2, 1979, entitled "NRC-South Texas Proceeding";

(c) The Memorandum to File from Rod Frame dated May 15, 1979, entitled "Lambe Memo of 4/6/79-NRC";

(d) The NRC Memorandum to Norman Lerner, Transcomm, from William Lambe, NRR-AIG, dated April 6, 1979, entitled "Our recent discussions with Roy Lessy re: The South Texas case (Prepared in Anticipation of a Hearing)"; and (e) The Transcomm Memorandum to File from Rodney W.

Frame dated June 26, 1979, entitled " Anti-competitive Effects of the Intrastate-only Restriction for Texas Electric Utilities".

7. Identify all documents which Robert Hartley or any person assisting him has provided to the Staff in connection with this proceeding. Identify documents in the possession or control of any person named or described in this Interrogatory

-to which the Staff has or had access, whether or not any such document has ever been in the possession or control of'the -

Staff.

8. Identify all documents which the Staff has provided to Robert Hartley or any person assisting him in connection I with this proceeding. Identify documents in the possession_

or control of the Staff to which any person named or described in this Interrogatory has or had access, whether or not any such document has ever been in the possession or control of such person.

Respectfully submitted, i

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~

William J. Frdnklin Attorney for Houston Lighting

& Power Company OF COUNSEL:

Baker & Botts 3000 One Shell Plaza Houston, Texas 77002 Lowenstein, Newman, Reis I Axelrad & Toll 1025 Connecticut Avenue, N.W.  !

20036  !

Washington, D.C. ,

Dated: February 1, 1980

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